T.C. Summary Opinion 2003-88
UNITED STATES TAX COURT
JOE GUADAGNO AND SUSAN BETH RISHEL GUADAGNO, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10312-01S. Filed July 9, 2003.
Joe Guadagno and Susan Beth Rishel Guadagno, pro sese.
T. Keith Fogg, for respondent.
CARLUZZO, Special Trial Judge: This case was heard pursuant
to the provisions of section 7463 of the Internal Revenue Code in
effect at the time the petition was filed. Unless otherwise
indicated, subsequent section references are to the Internal
Revenue Code in effect for the years in issue. The decision to
be entered is not reviewable by any other court, and this opinion
should not be cited as authority.
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